Within the field of financial risk management, professionals strive to develop models to tackle the complexities in the financial domain. However, due to the ever-changing nature of financial variables, models only capture reality to a certain extent. Therefore, model risk - the potential loss a business could suffer due to an inaccurate model or incorrect use of a model - is a pressing concern. This article explores model risk in prepayment models, analyzing various approaches to quantify and forecast this risk. 

There are numerous examples where model risk has not been properly accounted for, resulting in significant losses. For example, Long-Term Capital Management was a hedge fund that went bankrupt in the late 1990s because its model was never stress-tested for extreme market conditions. Similarly, in 2012, JP Morgan experienced a $6 billion loss and $920 million in fines due to flaws in its new value-at-risk model known as the ‘London Whale Trade’.  

Despite these prominent failures, and the requirements of CRD IV Article 85 for institutions to develop policies and processes for managing model risk,¹ the quantification and forecasting of model risk has not been extensively covered in academic literature. This leaves a significant gap in the general understanding and ability to manage this risk. Adequate model risk management allows for optimized capital allocation, reduced risk-related losses, and a strengthened risk culture.  

This article delves into model risk in prepayment models, examining different methods to quantify and predict this risk. The objective is to compare different approaches, highlighting their strengths and weaknesses.  

Definition of Model Risk

Generally, model risk can be assessed using a bottom-up approach by analyzing individual model components, assumptions, and inputs for errors, or by using a top-down approach by evaluating the overall impact of model inaccuracies on broader financial outcomes. In the context of prepayments, this article adopts a bottom-up approach by using model error as a proxy for model risk, allowing for a quantifiable measure of this risk. Model error is the difference between the modelled prepayment rate and the actual prepayment rate. Model error occurs at an individual level when a prepayment model predicts a prepayment that does not happen, and vice versa. However, banks are more interested in model error at the portfolio level. A statistic often used by banks is the Single Monthly Mortality (SMM). The SMM is the monthly percentage of prepayments and can be calculated by dividing the amount of prepayments for a given month by the total amount of mortgages outstanding. 

Using the SMM, we can define and calculate the model error as the difference between the predicted SMM and the actual SMM: 

The European Banking Authority (EBA) requires financial institutions when calculating valuation model risk to set aside enough funds to be 90% confident that they can exit a position at the time of the assessment. Consequently, banks are concerned with the top 5% and lowest 5% of the model risk distribution (EBA, 2016, 2015). ² Thus, banks are interested in the distribution of the model error as defined above, aiming to ensure they allocate the capital optimally for model risk in prepayment models.  

Approaches to Forecasting Model Risk 

By using model error as a proxy for model risk, we can leverage historical model errors to forecast future errors through time-series modelling. In this article, we explore three methods: the simple approach, the auto-regressive approach, and the machine learning challenger model approach.

Simple Approach

The first method proposed to forecast the expected value, and the variance of the model errors is the simple approach. It is the most straightforward way to quantify and predict model risk by analyzing the mean and standard deviation of the model errors. The model itself causes minimal uncertainty, as there are just two parameters which have to be estimated, namely the intercept and the standard deviation.

The disadvantage of the simple approach is that it is time-invariant. Consequently, even in extreme conditions, the expected value and the variance of model errors remain constant over time.

Auto-Regressive Approach

The second approach to forecast the model errors of a prepayment model is the auto-regressive approach. Specifically, this approach utilizes an AR(1) model, which forecasts the model errors by leveraging their lagged values. The advantage of the auto-regressive approach is that it takes into account the dynamics of the historical model errors when forecasting them, making it more advanced than the simple approach.

The disadvantage of the auto-regressive approach is that it always lags and that it does not take into account the current status of the economy. For example, an increase in the interest rate by 200 basis points is expected to lead to a higher model error, while the auto-regressive approach is likely to forecast this increase in model error one month later.

Machine Learning Challenger Model Approach                           

The third approach to forecast the model errors involves incorporating a Machine Learning (ML) challenger model. In this article, we use an Artificial Neural Network (ANN). This ML challenger model can be more sophisticated than the production model, as its primary focus is on predictive accuracy rather than interpretability. This approach uses risk measures to compare the production model with a more advanced challenger model. A new variable is defined as the difference between the production model and the challenger model.

Similar to the above approaches, the expected value of the model errors is forecasted by estimating the intercept, the parameter of the new variable, and the standard deviation. A forecast can be made and the difference between the production model and ML challenger model can be used as a proxy for future model risk.

The advantage of using the ML challenger model approach is that it is forward looking. This forward-looking method allows for reasonable estimates under both normal and extreme conditions, making it a reliable proxy for future model risk. In addition, when there are complex non-linear relationships between an independent variable and the prepayment rate, an ML challenger can be more accurate. Its complexity allows it to predict significant impacts better than a simpler, more interpretable production model. Consequently, employing an ML challenger model approach could effectively estimate model risk during substantial market changes.

A disadvantage of the machine learning approach is its complexity and lack of interpretability. Additionally, developing and maintaining these models often requires significant time, computational resources, and specialized expertise.

Conclusion 

The various methods to estimate model risk are compared in a simulation study. The ML challenger model approach stands out as the most effective method for predicting model errors, offering increased accuracy in both normal and extreme conditions. Both the simple and challenger model approach effectively predicts the variability of model errors, but the challenger model approach achieves a smaller standard deviation. In scenarios involving extreme interest rate changes, only the challenger model approach delivers reasonable estimates, highlighting its robustness. Therefore, the challenger model approach is the preferred choice for predicting model error under both normal and extreme conditions.

Ultimately, the optimal approach should align with the bank’s risk appetite, operational capabilities, and overall risk management framework. Zanders, with its extensive expertise in financial risk management, including multiple high-profile projects related to prepayments at G-SIBs as well as mid-size banks, can provide comprehensive support in navigating these challenges. See our expertise here.

Ready to take your IRRBB strategy to the next level?

Zanders is an expert on IRRBB-related topics. We enable banks to achieve both regulatory compliance and strategic risk goals by offering support from strategy to implementation. This includes risk identification, formulating a risk strategy, setting up an IRRBB governance and framework, and policy or risk appetite statements. Moreover, we have an extensive track record in IRRBB [EU1] and behavioral models such as prepayment models, hedging strategies, and calculating risk metrics, both from model development and model validation perspectives.

Contact our experts today to discover how Zanders can help you transform risk management into a competitive advantage. Reach out to: Jaap Karelse, Erik Vijlbrief, Petra van Meel, or Martijn Wycisk to start your journey toward financial resilience.

The Basel IV reforms, which are set to be implemented on 1 January 2025 via amendments to the EU Capital Requirement Regulation, have introduced changes to the Standardized Approach for credit risk (SA-CR). The Basel framework is implemented in the European Union mainly through the Capital Requirements Regulation (CRR3) and Capital Requirements Directive (CRD6). The CRR3 changes are designed to address shortcomings in the existing prudential standards, by among other items, introducing a framework with greater risk sensitivity and reducing the reliance on external ratings. Action by banks is required to remain compliant with the CRR. Overall, the share of RWEA derived through an external credit rating in the EU-27 remains limited, representing less than 10% of the total RWEA under the SA with the CRR.

Introduction

The Basel Committee on Banking Supervision (BCBS) identified the excessive dependence on external credit ratings as a flaw within the Standardised Approach (SA), observing that firms frequently used these ratings to compute Risk-Weighted Assets (RWAs) without adequately understanding the associated risks of their exposures. To address this issue, regulators have implemented changes aimed to reduce the mechanical reliance on external credit ratings and to encourage firms to use external credit ratings in a more informed manner. The objective is to diminish the chances of underestimating financial risks in order to further build a more resilient financial industry. Overall, the share of Risk Weighted Assets (RWA) derived through an external credit rating remains limited, and in Europe it represents less than 10% of the total RWA under the SA. 

The concept of due diligence is pivotal in the regulatory framework. It refers to the rigorous process financial institutions are expected to undertake to understand and assess the risks associated with their exposures fully. Regulators promote due diligence to ensure that banks do not solely rely on external assessments, such as credit ratings, but instead conduct their own comprehensive analysis.  

The due diligence is a process performed by banks with the aim of understanding the risk profile and characteristics of their counterparties at origination and thereafter on a regular basis (at least annually). This includes assessing the appropriateness of risk weights, especially when using external ratings. The level of due diligence should match the size and complexity of the bank's activities. Banks must evaluate the operating and financial performance of counterparties, using internal credit analysis or third-party analytics as necessary, and regularly access counterparty information. Climate-related financial risks should also be considered, and due diligence must be conducted both at the solo entity level and consolidated level. 

Banks must establish effective internal policies, processes, systems, and controls to ensure correct risk weight assignment to counterparties. They should be able to prove to supervisors that their due diligence is appropriate. Supervisors are responsible for reviewing these analyses and taking action if due diligence is not properly performed. 

Banks should have methodologies to assess credit risk for individual borrowers and at the portfolio level, considering both rated and unrated exposures. They must ensure that risk weights under the Standardised Approach reflect the inherent risk. If a bank identifies that an exposure, especially an unrated one, has higher inherent risk than implied by its assigned risk weight, it should factor this higher risk into its overall capital adequacy evaluation. 

Banks need to ensure they have an adequate understanding of their counterparties’ risk profiles and characteristics. The diligent monitoring of counterparties is applicable to all exposures under the SA. Banks would need to take reasonable and adequate steps to assess the operating and financial condition of each counterparty.

Rating System

The external credit assessment institutions (ECAIs) are credit rating agencies recognised by National supervisors. The External Credit ECAIs play a significant role in the SA through the mapping of each of their credit assessments to the corresponding risk weights. Supervisors will be responsible for assigning an eligible ECAI’s credit risk assessments to the risk weights available under the SA. The mapping of credit assessments should reflect the long-term default rate. 

Exposures to banks, exposures to securities firms and other financial institutions and exposures to corporates will be risk-weighted based on the following hierarchy External Credit Risk Assessment Approach (ECRA) and the Standardised Credit Risk Assessment Approach (SCRA). 

ECRA: Used in jurisdictions allowing external ratings. If an external rating is from an unrecognized or non-nominated ECAI, the exposure is considered unrated. Also, banks must perform due diligence to ensure ratings reflect counterparty creditworthiness and assign higher risk weights if due diligence reveals greater risk than the rating suggests. 

SCRA: Used where external ratings are not allowed. Applies to all bank exposures in these jurisdictions and unrated exposures in jurisdictions allowing external ratings. Banks classify exposures into three grades: 

• Grade A: Adequate capacity to meet obligations in a timely manner. 

• Grade B: Substantial credit risk, such as repayment capacities that are dependent on stable or favourable economic or business conditions. 

• Grade C: Higher credit risk, where the counterparty has material default risks and limited margins of safety 

The CRR Final Agreement includes a new article (Article 495e) that allows competent authorities to permit institutions to use an ECAI credit assessment assuming implicit government support until December 31, 2029, despite the provisions of Article 138, point (g). 

In cases where external credit ratings are used for risk-weighting purposes, due diligence should be used to assess whether the risk weight applied is appropriate and prudent.  

If the due diligence assessment suggests an exposure has higher risk characteristics than implied by the risk weight assigned to the relevant Credit Quality Step (CQS) of an exposure, the bank would assign the risk weight at least one higher than the CQS indicated by the counterparty’s external credit rating.

Criticisms to this approach are: 

1. Banks are mandated to use nominated ECAI ratings consistently for all exposures in an asset class, requiring banks to carry out a due diligence on each and every ECAI rating goes against the principle of consistent use of these ratings.  
2. When banks apply the output floor, ECAI ratings act as a backstop to internal ratings. In case the due diligence would imply the need to assign a high-risk weight, the output floor could no longer be used consistently across banks to compare capital requirements. 

Implementation Challenges

The regulation requires the bank to conduct due diligence to ensure a comprehensive understanding, both at origination and on a regular basis (at least annually), of the risk profile and characteristics of their counterparties. The challenges associated with implementing this regulation can be grouped into three primary categories: governance, business processes, and systems & data. 

Governance 

The existing governance framework must be enhanced to reflect the new responsibilities imposed by the regulation. This involves integrating the due diligence requirements into the overall governance structure, ensuring that accountability and oversight mechanisms are clearly defined. Additionally, it is crucial to establish clear lines of communication and decision-making processes to manage the new regulatory obligations effectively. 

Business Process 

A new business process for conducting due diligence must be designed and implemented, tailored to the size and complexity of the exposures. This process should address gaps in existing internal thresholds, controls, and policies. It is essential to establish comprehensive procedures that cover the identification, assessment, and monitoring of counterparties' risk profiles. This includes setting clear criteria for due diligence, defining roles and responsibilities, and ensuring that all relevant staff are adequately trained. 

Systems & Data 

The implementation of the regulation requires access to accurate and comprehensive data necessary for the rating system. Challenges may arise from missing or unavailable data, which are critical for assessing counterparties' risk profiles. Furthermore, reliance on manual solutions may not be feasible given the complexity and volume of data required. Therefore, it is imperative to develop robust data management systems that can capture, store, and analyse the necessary information efficiently. This may involve investing in new technology and infrastructure to automate data collection and analysis processes, ensuring data integrity and consistency. 

Overall, addressing these implementation challenges requires a coordinated effort across the organization, with a focus on enhancing governance frameworks, developing comprehensive business processes, and investing in advanced systems and data management solutions. 

How can Zanders help?  

As a trusted advisor, we built a track record of implementing CRR3 throughout a heterogeneous group of financial institutions. This provides us with an overview of how different entities in the industry deal with the different implementation challenges presented above.  

Zanders has been engaged to provide project management for these Basel IV implementation projects. By leveraging the expertise of Zanders' subject matter experts, we ensure an efficient and insightful gap analysis tailored to your bank's specific needs. Based on this analysis, combined with our extensive experience, we deliver customized strategic advice to our clients, impacting multiple departments within the bank. Furthermore, as an independent advisor, we always strive to challenge the status quo and align all stakeholders effectively. 

In-depth Portfolio Analysis: Our initial step involves conducting a thorough portfolio scan to identify exposures to both currently unrated institutions and those that rely solely on government ratings. This analysis will help in understanding the extent of the challenge and planning the necessary adjustments in your credit risk framework. 

Development of Tailored Models: Drawing from our extensive experience and industry benchmarks, Zanders will collaborate with your project team to devise a range of potential solutions. Each solution will be detailed with a clear overview of the required time, effort, potential impact on Risk-Weighted Assets (RWA), and the specific steps needed for implementation. Our approach will ensure that you have all the necessary information to make informed strategic decisions. 

Robust Solutions for Achieving Compliance: Our proprietary Credit Risk Suite cloud platform offers banks robust tools to independently assess and monitor the credit quality of corporate and financial exposures (externally rated or not) as well as determine the relevant ECRA and SCRA ratings. 

Strategic Decision-Making Support: Zanders will support your Management Team (MT) in the decision-making process by providing expert advice and impact analysis for each proposed solution. This support aims to equip your MT with the insights needed to choose the most appropriate strategy for your institution. 

Implementation Guidance: Once a decision has been made, Zanders will guide your institution through the specific actions required to implement the chosen solution effectively. Our team will provide ongoing support and ensure that the implementation is aligned with both regulatory requirements and your institution’s strategic objectives. 

Continuous Adaptation and Optimization: In response to the dynamic regulatory landscape and your bank's evolving needs, Zanders remains committed to advising and adjusting strategies as needed. Whether it's through developing an internal rating methodology, imposing new lending restrictions, or reconsidering business relations with unrated institutions, we ensure that your solutions are sustainable and compliant. 

Independent and Innovative Thinking: As an independent advisor, Zanders continuously challenges the status quo, pushing for innovative solutions that not only comply with regulatory demands but also enhance your competitive edge. Our independent stance ensures that our advice is unbiased and wholly in your best interest. 

By partnering with Zanders, you gain access to a team of dedicated professionals who are committed to ensuring your successful navigation through the regulatory complexities of Basel IV and CRR3. Our expertise and tailored approaches enable your institution to manage and mitigate risks efficiently while aligning with the strategic goals and operational realities of your bank. Reach out to Tim Neijs or Marco Zamboni for further comments or questions.

REFERENCE 

[1] BCBS, The Basel Framework, Basel https://www.bis.org/basel_framework 

[2] Regulation (EU) No 575/2013 

[3] Directive 2013/36/EU 

[4] EBA Roadmap on strengthening the prudential framework 

[5] EBA REPORT ON RELIANCE ON EXTERNAL CREDIT RATINGS 

The Covid-19 pandemic triggered unprecedented market volatility, causing widespread failures in banks' internal risk models. These backtesting failures threatened to increase capital requirements and restrict the use of advanced models. To avoid a potentially dangerous feedback loop from the lower liquidity, regulators responded by granting temporary exemptions for certain pandemic-related model exceptions. To act faster to future crises and reduce unreasonable increases to banks’ capital requirements, more recent regulation directly comments on when and how similar exemptions may be imposed.

Although FRTB regulation briefly comments on such situations of market stress, where exemptions may be imposed for backtesting and profit and loss attribution (PLA), it provides very little explanation of how banks can prove to the regulators that such a scenario has occurred. On 28^th June, the EBA published its final draft technical standards on extraordinary circumstances for continuing the use of internal models for market risk. These standards discuss the EBA’s take on these exemptions and provide some guidelines on which indicators can be used to identify periods of extreme market stresses.

Background and the BCBS

In the Basel III standards, the Basel Committee on Banking Supervision (BCBS) briefly comment on rare occasions of cross-border financial market stress or regime shifts (hereby called extreme stresses) where, due to exceptional circumstances, banks may fail backtesting and the PLA test. In addition to backtesting overages, banks often see an increasing mismatch between Front Office and Risk P&L during periods of extreme stresses, causing trading desks to fail PLA.

The BCBS comment that one potential supervisory response could be to allow the failing desks to continue using the internal models approach (IMA), however only if the banks models are updated to adequately handle the extreme stresses. The BCBS make it clear that the regulators will only consider the most extraordinary and systemic circumstances. The regulation does not, however, give any indication of what analysis banks can provide as evidence for the extreme stresses which are causing the backtesting or PLA failures.

The EBA’s standards

The EBA’s conditions for extraordinary circumstances, based on the BCBS regulation, provide some more guidance. Similar to the BCBS, the EBA’s main conditions are that a significant cross-border financial market stress has been observed or a major regime shift has taken place. They also agree that such scenarios would lead to poor outcomes of backtesting or PLA that do not relate to deficiencies in the internal model itself.

To assess whether the above conditions have been met, the EBA will consider the following criteria:

1. Analysis of volatility indices (such as the VIX and the VSTOXX), and indicators of realised volatilities, which are deemed to be appropriate to capture the extreme stresses,
2. Review of the above volatility analysis to check whether they are comparable to, or more extreme than, those observed during COVID-19 or the global financial crisis,
3. Assessment of the speed at which the extreme stresses took place,
4. Analysis of correlations and correlation indicators, which adequately capture the extreme stresses, and whether a significant and sudden change of them occurred,
5. Analysis of how statistical characteristics during the period of extreme stresses differ to those during the reference period used for the calibration of the VaR model.

The granularity of the criteria

The EBA make it clear that the standards do not provide an exhaustive list of suitable indicators to automatically trigger the recognition of the extreme stresses.  This is because they believe that cases of extreme stresses are very unique and would not be able to be universally captured using a small set of prescribed indicators.

They mention that defining a very specific set of indicators would potentially lead to banks developing automated or quasi-automated triggering mechanisms for the extreme stresses. When applied to many market scenarios, this may lead to a large number of unnecessary triggers due the specificity of the prescribed indicators. As such, the EBA advise that the analysis should take a more general approach, taking into consideration the uniqueness of each extreme stress scenario.

Responses to questions

The publication also summarises responses to the original Consultation Paper EBA/CP/2023/19. The responses discuss several different indicators or factors, on top of the suggested volatility indices, that could be used to identify the extreme stresses:

• The responses highlight the importance of correlation indicators. This is because stress periods are characterised by dislocations in the market, which can show increased correlations and heightened systemic risk.
• They also mention the use of liquidity indicators. This could include jumps of the risk-free rates (RFRs) or index swap (OIS) indicators. These liquidity indicators could be used to identify regime shifts by benchmarking against situations of significant cross-border market stress (for example, a liquidity crisis).
• Unusual deviations in the markets may also be strong indicators of the extreme stresses. For example, there could be a rapid widening of spreads between emerging and developed markets triggered by regional debt crisis. Unusual deviations between cash and derivatives markets or large difference between futures/forward and spot prices could also indicate extreme stresses.
• They suggest that restrictions on trading or delivery of financial instruments/commodities may be indicative of extreme stresses. For example, the restrictions faced by the Russian ruble due to the Russia-Ukraine war.
• Finally, the responses highlighted that an unusual amount of backtesting overages, for example more than 2 in a month, could also be a useful indicator.

Zanders recommends

It’s important that banks are prepared for potential extreme stress scenarios in the future. To achieve this, we recommend the following:

• Develop a holistic set of indicators and metrics that capture signs of potential extreme stresses,
• Use early warning signals to preempt potential upcoming periods of stress,
• Benchmark the indicators and metrics against what was observed during the great financial crisis and Covid-19,
• Create suitable reporting frameworks to ensure the knowledge gathered from the above points is shared with relevant teams, supporting early remediation of issues.

Conclusion

During extreme stresses such as Covid-19 and the global financial crisis, banks’ internal models can fail, not because of modelling issues but due to systemic market issues.  Under FRTB, the BCBS show that they recognise this and, in these rare situations, may provide exemptions. The EBA’s recently published technical standards provide better guidance on which indicators can be used to identify these periods of extreme stresses. Although they do not lay out a prescriptive and definitive set of indicators, the technical standards provide a starting point for banks to develop suitable monitoring frameworks.

For more information on this topic, contact Dilbagh Kalsi (Partner) or Hardial Kalsi (Manager).

Challenges with backtesting Expected Shortfall

Recent regulations are increasingly moving toward the use of Expected Shortfall (ES) as a measure to capture risk. Although ES fixes many issues with VaR, there are challenges when it comes to backtesting.

Although VaR has been widely-used for decades, its shortcomings have prompted the switch to ES. Firstly, as a percentile measure, VaR does not adequately capture tail risk. Unlike VaR, which gives the maximum expected portfolio loss in a given time period and at a specific confidence level, ES gives the average of all potential losses greater than VaR (see figure 1). Consequently, unlike Var, ES can capture a range of tail scenarios. Secondly, VaR is not sub-additive. ES, however, is sub-additive, which makes it better at accounting for diversification and performing attribution. As such, more recent regulation, such as FRTB, is replacing the use of VaR with ES as a risk measure.

Figure 1: Comparison of VaR and ES

Elicitability is a necessary mathematical condition for backtestability. As ES is non-elicitable, unlike VaR, ES backtesting methods have been a topic of debate for over a decade. Backtesting and validating ES estimates is problematic – how can a daily ES estimate, which is a function of a probability distribution, be compared with a realised loss, which is a single loss from within that distribution? Many existing attempts at backtesting have relied on approximations of ES, which inevitably introduces error into the calculations.

The three main issues with ES backtesting can be summarised as follows:

1. Transparency
   • Without reliable techniques for backtesting ES, banks struggle to have transparency on the performance of their models. This is particularly problematic for regulatory compliance, such as FRTB.
2. Sensitivity
   • Existing VaR and ES backtesting techniques are not sensitive to the magnitude of the overages. Instead, these techniques, such as the Traffic Light Test (TLT), only consider the frequency of overages that occur.
3. Stability
   • As ES is conditional on VaR, any errors in VaR calculation lead to errors in ES. Many existing ES backtesting methodologies are highly sensitive to errors in the underlying VaR calculations.

Ridge Backtesting: A solution to ES backtesting

One often-cited solution to the ES backtesting problem is the ridge backtesting approach. This method allows non-elicitable functions, such as ES, to be backtested in a manner that is stable with regards to errors in the underlying VaR estimations. Unlike traditional VaR backtesting methods, it is also sensitive to the magnitude of the overages and not just their frequency.

The ridge backtesting test statistic is defined as:

where 𝑣 is the VaR estimation, 𝑒 is the expected shortfall prediction, 𝑥 is the portfolio loss and 𝛼 is the confidence level for the VaR estimation.

The value of the ridge backtesting test statistic provides information on whether the model is over or underpredicting the ES. The technique also allows for two types of backtesting; absolute and relative. Absolute backtesting is denominated in monetary terms and describes the absolute error between predicted and realised ES. Relative backtesting is dimensionless and describes the relative error between predicted and realised ES. This can be particularly useful when comparing the ES of multiple portfolios. The ridge backtesting result can be mapped to the existing Basel TLT RAG zones, enabling efficient integration into existing risk frameworks.

Figure 2: The ridge backtesting methodology

Sensitivity to Overage Magnitude

Unlike VaR backtesting, which does not distinguish between overages of different magnitudes, a major advantage of ES ridge backtesting is that it is sensitive to the size of each overage. This allows for better risk management as it identifies periods with large overages and also periods with high frequency of overages.

Below, in figure 3, we demonstrate the effectiveness of the ridge backtest by comparing it against a traditional VaR backtest. A scenario was constructed with P&Ls sampled from a Normal distribution, from which a 1-year 99% VaR and ES were computed. The sensitivity of ridge backtesting to overage magnitude is demonstrated by applying a range of scaling factors, increasing the size of overages by factors of 1, 2 and 3. The results show that unlike the traditional TLT, which is sensitive only to overage frequency, the ridge backtesting technique is effective at identifying both the frequency and magnitude of tail events. This enables risk managers to react more quickly to volatile markets, regime changes and mismodelling of their risk models.

Figure 3: Demonstration of ridge backtesting’s sensitivity to overage magnitude.

The Benefits of Ridge Backtesting

Rapidly changing regulation and market regimes require banks enhance their risk management capabilities to be more reactive and robust. In addition to being a robust method for backtesting ES, ridge backtesting provides several other benefits over alternative backtesting techniques, providing banks with metrics that are sensitive and stable.

Despite the introduction of ES as a regulatory requirement for banks choosing the internal models approach (IMA), regulators currently do not require banks to backtest their ES models. This leaves a gap in banks’ risk management frameworks, highlighting the necessity for a reliable ES backtesting technique. Despite this, banks are being driven to implement ES backtesting methodologies to be compliant with future regulation and to strengthen their risk management frameworks to develop a comprehensive understanding of their risk.

Ridge backtesting gives banks transparency to the performance of their ES models and a greater reactivity to extreme events. It provides increased sensitivity over existing backtesting methodologies, providing information on both overage frequency and magnitude. The method also exhibits stability to any underlying VaR mismodelling.

In figure 4 below, we summarise the three major benefits of ridge backtesting.

Figure 4: The three major benefits of ridge backtesting.

Conclusion

The lack of regulatory control and guidance on backtesting ES is an obvious concern for both regulators and banks. Failure to backtest their ES models means that banks are not able to accurately monitor the reliability of their ES estimates. Although the complexities of backtesting ES has been a topic of ongoing debate, we have shown in this article that ridge backtesting provides a robust and informative solution. As it is sensitive to the magnitude of overages, it provides a clear benefit in comparison to traditional VaR TLT backtests that are only sensitive to overage frequency. Although it is not a regulatory requirement, regulators are starting to discuss and recommend ES backtesting. For example, the PRA, EBA and FED have all recommended ES backtesting in some of their latest publications. However, despite the fact that regulation currently only requires banks to perform VaR backtesting, banks should strive to implement ES backtesting as it supports better risk management.

For more information on this topic, contact Dilbagh Kalsi (Partner) or Hardial Kalsi (Manager).

Across the whole of Europe, banks apply different techniques to model their IFRS9 Expected Credit Losses on a best estimate basis. The diverse spectrum of modelling techniques raises the question: what can we learn from each other, such that we all can improve our own IFRS 9 frameworks? For this purpose, Zanders hosted a webinar on the topic of IFRS 9 on the 29^th of May 2024. This webinar was in the form of a panel discussion which was led by Martijn de Groot and tried to discuss the differences and similarities by covering four different topics. Each topic was discussed by one  panelist, who were Pieter de Boer (ABN AMRO, Netherlands), Tobia Fasciati (UBS, Switzerland), Dimitar Kiryazov (Santander, UK), and Jakob Lavröd (Handelsbanken, Sweden).

The webinar showed that there are significant differences with regards to current IFRS 9 issues between European banks. An example of this is the lingering effect of the COVID-19 pandemic, which is more prominent in some countries than others. We also saw that each bank is working on developing adaptable and resilient models to handle extreme economic scenarios, but that it remains a work in progress. Furthermore, the panel agreed on the fact that SICR remains a difficult metric to model, and, therefore, no significant changes are to be expected on SICR models.

Covid-19 and data quality

The first topic covered the COVID-19 period and data quality. The poll question revealed widespread issues with managing shifts in their IFRS 9 model resulting from the COVID-19 developments. Pieter highlighted that many banks, especially in the Netherlands, have to deal with distorted data due to (strong) government support measures. He said this resulted in large shifts of macroeconomic variables, but no significant change in the observed default rate. This caused the historical data not to be representative for the current economic environment and thereby distorting the relationship between economic drivers and credit risk. One possible solution is to exclude the COVID-19 period, but this will result in the loss of data. However, including the COVID-19 period has a significant impact on the modelling relations. He also touched on the inclusion of dummy variables, but the exact manner on how to do so remains difficult.

Dimitar echoed these concerns, which are also present in the UK. He proposed using the COVID-19 period as an out-of-sample validation to assess model performance without government interventions. He also talked about the problems with the boundaries of IFRS 9 models. Namely, he questioned whether models remain reliable when data exceeds extreme values. Furthermore, he mentioned it also has implications for stress testing, as COVID-19 is a real life stress scenario, and we might need to think about other modelling techniques, such as regime-switching models.

Jakob found the dummy variable approach interesting and also suggested the Kalman filter or a dummy variable that can change over time. He pointed out that we need to determine whether the long term trend is disturbed or if we can converge back to this trend. He also mentioned the need for a common data pipeline, which can also be used for IRB models. Pieter and Tobia agreed, but stressed that this is difficult since IFRS 9 models include macroeconomic variables and are typically more complex than IRB.

Significant Increase in Credit Risk

The second topic covered the significant increase in credit risk (SICR). Jakob discussed the complexity of assessing SICR and the lack of comprehensive guidance. He stressed the importance of looking at the origination, which could give an indication on the additional risk that can be sustained before deeming a SICR.

Tobia pointed out that it is very difficult to calibrate, and almost impossible to backtest SICR. Dimitar also touched on the subject and mentioned that the SICR remains an accounting concept that has significant implications for the P&L. The UK has very little regulations on this subject, and only requires banks to have sufficient staging criteria. Because of these reasons, he mentioned that he does not see the industry converging anytime soon. He said it is going to take regulators to incentivize banks to do so. Dimitar, Jakob, and Tobia also touched upon collective SICR, but all agreed this is difficult to do in practice.

Post Model Adjustments

The third topic covered post model adjustments (PMAs). The results from the poll question implied that most banks still have PMAs in place for their IFRS 9 provisions. Dimitar responded that the level of PMAs has mostly reverted back to the long term equilibrium in the UK. He stated that regulators are forcing banks to reevaluate PMAs by requiring them to identify the root cause. Next to this, banks are also required to have a strategy in place when these PMAs are reevaluated or retired, and how they should be integrated in the model risk management cycle. Dimitar further argued that before COVID-19, PMAs were solely used to account for idiosyncratic risk, but they stayed around for longer than anticipated. They were also used as a countercyclicality, which is unexpected since IFRS 9 estimations are considered to be procyclical. In the UK, banks are now building PMA frameworks which most likely will evolve over the coming years.

Jakob stressed that we should work with PMAs on a parameter level rather than on ECL level to ensure more precise adjustments. He also mentioned that it is important to look at what comes before the modelling, so the weights of the scenarios. At Handelsbanken, they first look at smaller portfolios with smaller modelling efforts. For the larger portfolios, PMAs tend to play less of a role. Pieter added that PMAs can be used to account for emerging risks, such as climate and environmental risks, that are not yet present in the data. He also stressed that it is difficult to find a balance between auditors, who prefer best estimate provisions, and the regulator, who prefers higher provisions.

Linking IFRS 9 with Stress Testing Models

The final topic links IFRS 9 and stress testing. The poll revealed that most participants use the same models for both. Tobia discussed that at UBS the IFRS 9 model was incorporated into their stress testing framework early on. He pointed out the flexibility when integrating forecasts of ECL in stress testing. Furthermore, he stated that IFRS 9 models could cope with stress given that the main challenge lies in the scenario definition. This is in contrast with others that have been arguing that IFRS 9 models potentially do not work well under stress. Tobia also mentioned that IFRS 9 stress testing and traditional stress testing need to have aligned assumptions before integrating both models in each other.

Jakob agreed and talked about the perfect foresight assumption, which suggests that there is no need for additional scenarios and just puts a weight of 100% on the stressed scenario. He also added that IFRS 9 requires a non-zero ECL, but a highly collateralized portfolio could result in zero ECL. Stress testing can help to obtain a loss somewhere in the portfolio, and gives valuable insights on identifying when you would take a loss. 

Pieter pointed out that IFRS 9 models differ in the number of macroeconomic variables typically used. When you are stress testing variables that are not present in your IFRS 9 model, this could become very complicated. He stressed that the purpose of both models is different, and therefore integrating both can be challenging. Dimitar said that the range of macroeconomic scenarios considered for IFRS 9 is not so far off from regulatory mandated stress scenarios in terms of severity. However, he agreed with Pieter that there are different types of recessions that you can choose to simulate through your IFRS 9 scenarios versus what a regulator has identified as systemic risk for an industry. He said you need to consider whether you are comfortable relying on your impairment models for that specific scenario.

This topic concluded the webinar on differences and similarities across European countries regarding IFRS 9. We would like to thank the panelists for the interesting discussion and insights, and the more than 100 participants for joining this webinar.

Interested to learn more? Contact Kasper Wijshoff, Michiel Harmsen or Polly Wong for questions on IFRS 9.

Model risk from risk models has become a focal point of discussion between regulators and the banking industry. As financial institutions strive to enhance their model risk management practices, the need for robust model risk quantification becomes paramount.​​

An introduction to model risk quantification​

Many firms already have comprehensive model risk management frameworks that tier models using an ordinal rating (such as high/medium/low risk). However, this provides limited information on potential losses due to model risk or the capital cost of already identified model risks. Model risk quantification uses quantitative techniques to bridge this gap and calculate the potential impact of model risk on a business. ​

The goal of a model risk quantification framework​

As with many other sources of risk within a financial institute, the aim is to manage risk by holding capital against potential losses from the use of individual models across the firm. This can be achieved by including model risk as a component of Pillar 2 within the Internal Capital Adequacy Assessment Process (ICAAP).​

Blockers impeding model risk quantification

Complications of quantification include:​​

• Implementation and running costs: Setting up and regularly running any quantification test involves significant resource costs. ​
• Uncovered risk: Trying to quantify all potential model risk is a Sisyphean task.​
• Internal resistance: Quantification and capitalisation of model risks will require increased resources to produce, leading to higher costs, making it a hard initiative to motivate individuals to follow.

Concepts in Model Risk Quantification​

Impacts of Model Risk​

Model risk significantly influences financial institutions through valuations, capital requirements, and overall risk management strategies. The uncertainties tied to model outcomes can have profound impacts on regulatory compliance, economic capital, and the firm's standing in the financial ecosystem.​

Model tiering​

Model tiering is a qualitative exercise that assesses the holistic risk of a model by considering various factors (e.g. materiality, importance, complexity, transparency, operational intricacies, and controls).​

The tiering output grades the risk of a model on an ordinal scale, comparing it to other models within the institute. However, it doesn't provide a quantitative metric that can be aggregated with other models.​

Overlap with quantitative regulations​

Most firms already perform quantitative processes to measure the performance of Pillar 1 models that impact the regulatory capital held (such as the VaR backtesting multiplier applied to market risk RWA).​

Model Risk Quantification Framework​ - The Model Uncertainty Approach​

A crucial step in building a robust model risk quantification framework is classifying and assessing the impact of model risk. The model uncertainty approach is an internal quantitative approach in which model risks are identified and quantified on an individual level. Individual model risks are subsequently aggregated and translated into a monetary impact on the bank.   

​Regulatory Model Risk Quantificaiton Methods​ - RNIV, Backtesting Multiplier, Prudent Valuation and MoC​

Most banks are already familiar with quantification techniques recommend by regulators for risk management. Below we highlight some of these techniques that can be used as the basis for expansion of quantification within a firm. ​

Expanding Model Risk Quantification​

Our approach to efficient measurement relies on two key components. The first is model risk classifications to prioritize models to quantify, and the second is a knowledge base of already implemented regulatory and internally developed techniques to quantify that risk. This approach provides good risk coverage whilst also being extremely resource efficient.​

Looking to learn more about Model Risk Management? Reach out to our experts Dr. Andreas Peter, Alexander Mottram, Hisham Mirza.

Under FRTB regulation, PLA requires banks to assess the similarity between Front Office (FO) and Risk P&L (HPL and RTPL) on a quarterly basis. Desks which do not pass PLA incur capital surcharges or may, in more severe cases, be required to use the more conservative FRTB standardised approach (SA).​

What is the purpose of PLA?​

PLA ensures that the FO and Risk P&Ls are sufficiently aligned with one another at the desk level.​ The FO HPL is compared with the Risk RTPL using two statistical tests.​ The tests measure the materiality of any simplifications in a bank’s Risk model compared with the FO systems.​ In order to use the Internal Models Approach (IMA), FRTB requires each trading desk to pass the PLA statistical tests.​ Although the implementation of PLA begins on the date that the IMA capital requirement becomes effective, banks must provide a one-year PLA test report to confirm the quality of the model.

Which statistical measures are used?​

PLA is performed using the Spearman Correlation and the Kolmogorov-Smirnov (KS) test using the most recent 250 days of historical RTPL and HPL.​ Depending on the results, each desk is assigned a traffic light test (TLT) zone (see below), where amber desks are those which are allocated to neither red or green.​

What are the consequences of failing PLA?

Capital increase: Desks in the red zone are not permitted to use the IMA and must instead use the more conservative SA, which has higher capital requirements. ​Amber desks can use the IMA but must pay a capital surcharge until the issues are remediated.

Difficulty with returning to IMA: Desks which are in the amber or red zone must satisfy statistical green zone requirements and 12-month backtesting requirements before they can be eligible to use the IMA again.​

What are some of the key reasons for PLA failure?

Data issues: Data proxies are often used within Risk if there is a lack of data available for FO risk factors. Poor or outdated proxies can decrease the accuracy of RTPL produced by the Risk model.​ The source, timing and granularity also often differs between FO and Risk data.

Missing risk factors: Missing risk factors in the Risk model are a common cause of PLA failures. Inaccurate RTPL values caused by missing risk factors can cause discrepancies between FO and Risk P&Ls and lead to PLA failures.

Roadblocks to finding the sources of PLA failures

FO and Risk mapping: Many banks face difficulties due to a lack of accurate mapping between risk factors in FO and those in Risk. ​For example, multiple risk factors in the FO systems may map to a single risk factor in the Risk model. More simply, different naming conventions can also cause issues.​ The poor mapping can make it difficult to develop an efficient and rapid process to identify the sources of P&L differences.

Lack of existing processes: PLA is a new requirement which means there is a lack of existing infrastructure to identify causes of P&L failures. ​Although they may be monitored at the desk level, P&L differences are not commonly monitored at the risk factor level on an ongoing basis.​ A lack of ongoing monitoring of risk factors makes it difficult to pre-empt issues which may cause PLA failures and increase capital requirements.

Our approach: Identifying risk factors that are causing PLA failures

Zanders’ approach overcomes the above issues by producing analytics despite any underlying mapping issues between FO and Risk P&L data. ​Using our algorithm, risk factors are ranked depending upon how statistically likely they are to be causing differences between HPL and RTPL.​ Our metric, known as risk factor ‘alpha’, can be tracked on an ongoing basis, helping banks to remediate underlying issues with risk factors before potential PLA failures.

Zanders’ P&L attribution solution has been implemented at a Tier-1 bank, providing the necessary infrastructure to identify problematic risk factors and improve PLA desk statuses. The solution provided multiple benefits to increase efficiency and transparency of workstreams at the bank.

Conclusion

As it is a new regulatory requirement, passing the PLA test has been a key concern for many banks. Although the test itself is not considerably difficult to implement, identifying why a desk may be failing can be complicated. In this article, we present a PLA tool which has already been successfully implemented at one of our large clients. By helping banks to identify the underlying risk factors which are causing desks to fail, remediation becomes much more efficient. Efficient remediation of desks which are failing PLA, in turn, reduces the amount of capital charges which banks may incur.

Challenges with VaR models in a turbulent market​

With recent periods of market stress, including COVID-19 and the Russia-Ukraine conflict, banks are finding their VaR models under strain. A failure to adhere to VaR backtesting requirements can lead to pressure on balance sheets through higher capital requirements and interventions from the regulator.

VaR backtesting

VaR is integral to the capital requirements calculation and in ensuring a sufficient capital buffer to cover losses from adverse market conditions.​ The accuracy of VaR models is therefore tested stringently with VaR backtesting, comparing the model VaR to the observed hypothetical P&Ls. ​A VaR model with poor backtesting performance is penalised with the application of a capital multiplier, ensuring a conservative capital charge.​ The capital multiplier increases with the number of exceptions during the preceding 250 business days, as described in Table 1 below.​

Table 1: Capital multipliers based on the number of backtesting exceptions.

The capital multiplier is applied to both the VaR and stressed VaR, as shown in equation 1 below, which can result in a significant impact on the market risk capital requirement when failures in VaR backtesting occur.​

Pro-cyclicality of the backtesting framework​

A known issue of VaR backtesting is pro-cyclicality in market risk. ​This problem was underscored at the beginning of the COVID-19 outbreak when multiple banks registered several VaR backtesting exceptions. ​This had a double impact on market risk capital requirements, with higher capital multipliers and an increase in VaR from higher market volatility.​ Consequently, regulators intervened to remove additional pressure on banks’ capital positions that would only exacerbate market volatility. The Federal Reserve excluded all backtesting exceptions between 6th – 27th March 2020, while the PRA allowed a proportional reduction in risks-not-in-VaR (RNIV) capital charge to offset the VaR increase.​ More recent market volatility however has not been excluded, putting pressure on banks’ VaR models during backtesting.​

Historical simulation VaR model challenges​

Banks typically use a historical simulation approach (HS VaR) for modelling VaR, due to its computational simplicity, non-normality assumption of returns and enhanced interpretability. ​Despite these advantages, the HS VaR model can be slow to react to changing markets conditions and can be limited by the scenario breadth. ​This means that the HS VaR model can fail to adequately cover risk from black swan events or rapid shifts in market regimes.​ These issues were highlighted by recent market events, including COVID-19, the Russia-Ukraine conflict, and the global surge in inflation in 2022.​ Due to this, many banks are looking at enriching their VaR models to better model dramatic changes in the market.

Enriching HS VaR models​

Alternative VaR modelling approaches can be used to enrich HS VaR models, improving their response to changes in market volatility. Volatility scaling is a computationally efficient methodology which can resolve many of the shortcomings of HS VaR model, reducing backtesting failures.​

Enhancing HS VaR with volatility scaling​

The Volatility Scaling methodology is an extension of the HS VaR model that addresses the issue of inertia to market moves.​ Volatility scaling adjusts the returns for each time t by the volatility ratio σT/σt, where σt is the return volatility at time t and σT is the return volatility at the VaR calculation date.​ Volatility is calculated using a 30-day window, which more rapidly reacts to market moves than a typical 1Y VaR window, as illustrated in Figure 1.​ As the cost of underestimation is higher than overestimating VaR, a lower bound to the volatility ratio of 1 is applied.​ Volatility scaling is simple to implement and can enrich existing models with minimal additional computational overhead.​

Figure 1: The 30-day and 1Y rolling volatilities of the 1-day scaled diversified portfolio returns. This illustrates recent market stresses, with short regions of extreme volatility (COVID-19) and longer systemic trends (Russia-Ukraine conflict and inflation). 

Comparison with alternative VaR models​

To benchmark the Volatility Scaling approach, we compare the VaR performance with the HS and the GARCH(1,1) parametric VaR models.​ The GARCH(1,1) model is configured for daily data and parameter calibration to increase sensitivity to market volatility.​ All models use the 99th percentile 1-day VaR scaled by a square root of 10. ​The effective calibration time horizon is one year, approximated by a VaR window of 260 business days.​ A one-week lag is included to account for operational issues that banks may have to load the most up-to-date market data into their risk models.​

VaR benchmarking portfolios​

To benchmark the VaR Models, their performance is evaluated on several portfolios that are sensitive to the equity, rates and credit asset classes. ​These portfolios include sensitivities to: S&P 500 (Equity), US Treasury Bonds (Treasury), USD Investment Grade Corporate Bonds (IG Bonds) and a diversified portfolio of all three asset classes (Diversified).​ This provides a measure of the VaR model performance for both diversified and a range of concentrated portfolios.​ The performance of the VaR models is measured on these portfolios in both periods of stability and periods of extreme market volatility. ​This test period includes COVID-19, the Russia-Ukraine conflict and the recent high inflationary period.​

VaR model benchmarking

The performance of the models is evaluated with VaR backtesting. The results show that the volatility scaling provides significantly improved performance over both the HS and GARCH VaR models, providing a faster response to markets moves and a lower instance of VaR exceptions.​

Model benchmarking with VaR backtesting​

A key metric for measuring the performance of VaR models is a comparison of the frequency of VaR exceptions with the limits set by the Basel Committee’s Traffic Light Test (TLT). ​Excessive exceptions will incur an increased capital multiplier for an Amber result (5 – 9 exceptions) and an intervention from the regulator in the case of a Red result (ten or more exceptions).​ Exceptions often indicate a slow reaction to market moves or a lack of accuracy in modelling risk.​

VaR measure coverage​

The coverage and adaptability of the VaR models can be observed from the comparison of the realised returns and VaR time series shown in Figure 2.​ This shows that although the GARCH model is faster to react to market changes than HS VaR, it underestimates the tail risk in stable markets, resulting in a higher instance of exceptions.​ Volatility scaling retains the conservatism of the HS VaR model whilst improving its reactivity to turbulent market conditions. This results in a significant reduction in exceptions throughout 2022.​

Figure 2: Comparison of realised returns with the model VaR measures for a diversified portfolio.

VaR backtesting results​

The VaR model performance is illustrated by the percentage of backtest days with Red, Amber and Green TLT results in Figure 3.​ Over this period HS VaR shows a reasonable coverage of the hypothetical P&Ls, however there are instances of Red results due to the failure to adapt to changes in market conditions.​ The GARCH model shows a significant reduction in performance, with 32% of test dates falling in the Red zone as a consequence of VaR underestimation in calm markets.​ The adaptability of volatility scaling ensures it can adequately cover the tail risk, increasing the percentage of Green TLT results and completely eliminating Red results.​ In this benchmarking scenario, only volatility scaling would pass regulatory scrutiny, with HS VaR and GARCH being classified as flawed models, requiring remediation plans.

Figure 3: Percentage of days with a Red, Amber and Green Traffic Light Test result for a diversified portfolio over the window 29/01/21 - 31/01/23.

VaR model capital requirements​

Capital requirements are an important determinant in banks’ ability to act as market intermediaries. The volatility scaling method can be used to increase the HS capital deployment efficiency without compromising VaR backtesting results.​

Capital requirements minimisation​

A robust VaR model produces risk measures that ensure an ample capital buffer to absorb portfolio losses. When selecting between robust VaR models, the preferred approach generates a smaller capital charge throughout the market cycle. Figure 4 shows capital requirements for the VaR models for a diversified portfolio calculated using Equation 1, with 𝐴𝑑𝑑𝑜𝑛𝑠 set to zero. Volatility scaling outperforms both models during extreme market volatility (the Russia-Ukraine conflict) and the HS model in period of stability (2021) as a result of setting the lower scaling constraint. The GARCH model underestimates capital requirements in 2021, which would have forced a bank to move to a standardised approach.

Figure 4: Capital charge for the VaR models measured on a diversified portfolio over the window 29/01/21 - 31/01/23.

Capital management efficiency

Pro-cyclicality of capital requirements is a common concern among regulators and practitioners. More stable requirements can improve banks’ capital management and planning. To measure models’ pro-cyclicality and efficiency, average capital charges and capital volatilities are compared for three concentrated asset class portfolios and a diversified market portfolio, as shown in Table 2. Volatility scaling results are better than the HS model across all portfolios, leading to lower capital charges, volatility and more efficient capital allocation. The GARCH model tends to underestimate high volatility and overestimate low volatility, as seen by the behaviour for the lowest volatility portfolio (Treasury).

Table 2: Average capital requirement and capital volatility for each VaR model across a range of portfolios during the test period, 29/01/21 - 31/01/23.

Conclusions on VaR backtesting

Recent periods of market stress highlighted the need to challenge banks’ existing VaR models. Volatility scaling is an efficient method to enrich existing VaR methodologies, making them robust across a range of portfolios and volatility regimes.

VaR backtesting in a volatile market

Ensuring VaR models conform to VaR backtesting will be challenging with the recent period of stressed market conditions and rapid changes in market volatility. Banks will need to ensure that their VaR models are responsive to volatility clustering and tail events or enhance their existing methodology to cope. Failure to do so will result in additional overheads, with increased capital charges and excessive exceptions that can lead to additional regulatory scrutiny.

Enriching VaR Models with volatility scaling

Volatility scaling provides a simple extension of HS VaR that is robust and responsive to changes in market volatility. The model shows improved backtesting performance over both the HS and parametric (GARCH) VaR models. It is also robust for highly concentrated equity, treasury and bond portfolios, as seen in Table 3. Volatility scaling dampens pro-cyclicality of HS capital requirements, ensuring more efficient capital planning. The additional computational overhead is minimal and the implementation to enrich existing models is simple. Performance can be further improved with the use of hybrid models which incorporate volatility scaling approaches. These can utilise outlier detection to increase conservatism dynamically with increasingly volatile market conditions.

Table 3: Percentage of Green, Amber and Red traffic Lights test results for each VaR model across a range of portfolios for dates in the range: 13/02/19 - 31/01/23.

Zanders recommends

Banks should invest in making their VaR models more robust and reactive to ensure capital costs and the probability of exceptions are minimised. VaR models enriched with a volatility scaling approach should be considered among a suite of models to challenge existing VaR model methodologies. Methods similar to volatility scaling can also be applied to parametric and semi-parametric models. Outlier detection models can be used to identify changes in market regime as either feeder models or early warning signals for risk managers

During the development of these models an important step is the calibration of the parameters to ensure a good model performance. In order to maintain these models a regular re-calibration is performed. For our Credit Rating models we strive to rely on a quantitative calibration approach that is combined and strengthened with expert option. This article explains the calibration process for one of our Credit Risk models, the Corporate Rating Model.

In short, the Corporate Rating Model assigns a credit rating to a company based on its performance on quantitative and qualitative variables. The quantitative part consists of 5 financial pillars; Operations, Liquidity, Capital Structure, Debt Service and Size. The qualitative part consist of 2 pillars; Business Analysis pillar and Behavioural Analysis pillar. See A comprehensive guide to Credit Rating Modelling for more details on the methodology behind this model.

The model calibration process for the Corporate Rating Model can be summarized as follows:

Figure 1: Overview of the model calibration process

In steps (2) through (7), input from the Zanders expert group is taken into consideration. This especially holds for input parameters that cannot be directly derived by a quantitative analysis. For these parameters, first an expert-based baseline value is determined and second a model performance optimization is performed to set the final model parameters.

In most steps the model performance is accessed by looking at the AUC (area under the ROC curve). The AUC metric is one of the most popular metrics to quantify the model fit (note this is not necessarily the same as the model quality, just as correlation does not equal causation). The AUC metric indicates, very simply put, the number of correct and incorrect predictions and plots them in a graph. The area under that graph then indicates the explanatory power of the model

DATA

The first step covers the selection of data from an extensive database containing the financial information and default history of millions of companies. Not all data points can be used in the calibration and/or during the performance testing of the model, therefore data filters are applied. Furthermore, the data set is categorized in 3 different size classes and 18 different industry sectors, each of which will be calibrated independently, using the same methodology.

This results in the master dataset, in addition data statistics are created that show the data availability, data relations and data quality. The master dataset also contains derived fields based on financials from the database, these fields are based on a long list of quantitative risk drivers (financial ratios). The long list of risk drivers is created based on expert option. As a last step, the master dataset is split into a calibration dataset (2/3 of the master dataset) and a test dataset (1/3 of the master dataset).

RISK DRIVER SELECTION

The risk driver selection for the qualitative variables is different from the risk driver selection for the quantitative variables. The final list of quantitative risk drivers is selected by means of different statistical analyses calculated for the long list of quantitative risk drivers. For the qualitative variables, a set of variables is selected based on expert opinion and industry practices.

SCORING APPROACH

Scoring functions are calibrated for the quantitative part of the model. These scoring function translate the value and trend value of each quantitative risk driver per size and industry to a (uniform) score between 0-100. For this exercise, different possible types of scoring functions are used. The best-performing scoring function for the value and trend of each risk driver is determined by performing a regression and comparing the performance. The coefficients in the scoring functions are estimated by fitting the function to the ratio values for companies in the calibration dataset. For the qualitative variables the translation from a value to a score is based on expert opinion.

WEIGHTING APPROACH

The overall score of the quantitative part of the model is combined by summing the value and trend scores by applying weights. As a starting point expert opinion-based weights are applied, after which the performance of the model is further optimized by iteratively adjusting the weights and arriving at an optimal set of weights. The weights of the qualitative variables are based on expert opinion.

MAPPING TO CENTRAL TENDENCY

To estimate the mapping from final scores to a rating class, a standardized methodology is created. The buckets are constructed from a scoring distribution perspective. This is done to ensure the eventual smooth distribution over the rating classes. As an input, the final scores (based on the quantitative risk drivers only) of each company in the calibration dataset is used together with expert opinion input parameters. The estimation is performed per size class. An optimization is performed towards a central tendency by adjusting the expert opinion input parameters. This is done by deriving a target average PD range per size class and on total level based on default data from the European Banking Authority (EBA).

The qualitative variables are included by performing an external benchmark on a selected set of companies, where proxies are used to derive the score on the qualitative variables.

The final input parameters for the mapping are set such that the average PD per size class from the Corporate Rating Model is in line with the target average PD ranges. And, a good performance on the external benchmark is achieved.

OVERRIDE FRAMEWORK

The override framework consists of two sections, Level A and Level B. Level A takes country, industry and company-specific risks into account. Level B considers the possibility of guarantor support and other (final) overriding factors. By applying Level A overrides, the Interim Credit Risk Rating (CRR) is obtained. By applying Level B overrides, the Final CRR is obtained. For the calibration only the country risk is taken into account, as this is the only override that is based on data and not a user input. The country risk is set based on OECD country risk classifications.

TESTING AND BENCHMARKING

For the testing and benchmarking the performance of the model is analysed based on the calibration and test dataset (excluding the qualitative assessment but including the country risk adjustment). For each dataset the discriminatory power is determined by looking at the AUC. The calibration quality is reviewed by performing a Binomial Test on Individual Rating Classes to check if the observed default rate lies within the boundaries of the PD rating class and a Traffic Lights Approach to compare the observed default rates with the PD of the rating class.

Concluding, the methodology applied for the (re-)calibration of the Corporate Rating Model is based on an extensive dataset with financial and default information and complemented with expert opinion. The methodology ensures that the final model performs in-line with the central tendency and an performs well on an external benchmark.

For all the criticism that rating models and credit rating agencies have had through the years, they are still the most pragmatic and realistic approach for assessing default risk for your counterparties. Of course, the quality of the assessment depends to a large extent on the quality of the model used to determine the credit rating, capturing both the quantitative and qualitative factors determining counterparty credit risk. A sound credit rating model strikes a balance between these two aspects. Relying too much on quantitative outcomes ignores valuable ‘unstructured’ information, whereas an expert judgement based approach ignores the value of empirical data, and their explanatory power.

In this white paper we will outline some best practice approaches to assessing default risk of a company through a credit rating. We will explore the ratios that are crucial factors in the model and provide guidance for the expert judgement aspects of the model.

Zanders has applied these best practices while designing several Credit Rating models for many years. These models are already being used at over 400 companies and have been tested both in practice and against empirical data. Do you want to know more about our Credit Rating models, click here.

Credit ratings and their applications

Credit ratings are widely used throughout the financial industry, for a variety of applications. This includes the corporate finance, risk and treasury domains and beyond. While it is hardly ever a sole factor driving management decisions, the availability of a point estimation to describe something as complex as counterparty credit risk has proven a very useful piece of information for making informed decisions, without the need for a full due diligence into the books of the counterparty.

Some of the specific use cases are:

• Internal assessment of the creditworthiness of counterparties
• Transparency of the creditworthiness of counterparties
• Monitoring trends in the quality of credit portfolios
• Monitoring concentration risk
• Performance measurement
• Determination of risk-adjusted credit approval levels and frequency of credit reviews
• Formulation of credit policies, risk appetite, collateral policies, etc.
• Loan pricing based on Risk Adjusted Return on Capital (RAROC) and Economic Profit (EP)
• Arm’s length pricing of intercompany transactions, in line with OECD guidelines
• Regulatory Capital (RC) and Economic Capital (EC) calculations
• Expected Credit Loss (ECL) IFRS 9 calculations
• Active Credit Portfolio Management on both portfolio and (individual) counterparty level

Credit rating philosophy

A fundamental starting point when applying credit ratings, is the credit rating philosophy that is followed. In general, two distinct approaches are recognized:

• Through-the-Cycle (TtC) rating systems measure default risk of a counterparty by taking permanent factors, like a full economic cycle, into account based on a worst-case scenario. TtC ratings change only if there is a fundamental change in the counterparty’s situation and outlook. The models employed for the public ratings published by e.g. S&P, Fitch and Moody’s are generally more TtC focused. They tend to assign more weight to qualitative features and incorporate longer trends in the financial ratios, both of which increase stability over time.
• Point-in-Time (PiT) rating systems measure default risk of a counterparty taking current, temporary factors into account. PiT ratings tend to adjust quickly to changes in the (financial) conditions of a counterparty and/or its economic environment. PiT models are more suited for shorter term risk assessments, like Expected Credit Losses. They are more focused on financial ratios, thereby capturing the more dynamic variables. Furthermore, they incorporate a shorter trend which adjusts faster over time. Most models incorporate a blend between the two approaches, acknowledging that both short term and long term effects may impact creditworthiness.

Rating methodology

Modelling credit ratings is very complex, due to the wide variety of events and exposures that companies are exposed to. Operational risk, liquidity risk, poor management, a perishing business model, an external negative event, failing governments and technological innovation can all have very significant influence on the creditworthiness of companies in the short and long run. Most credit rating models therefore distinguish a range of different factors that are modelled separately and then combined into a single credit rating. The exact factors will differ per rating model. The overview below presents the factors included the Corporate Rating Model, which is used in some of the cloud-based solutions of the Zanders applications.

The remainder of this article will detail the different factors, explaining the rationale behind including them.

Quantitative factors

Quantitative risk factors are crucial to credit rating models, as they are ‘objective’ and therefore generate a large degree of comparability between different companies. Their objective nature also makes them easier to incorporate in a model on a large scale. While financials alone do not tell the whole story about a company, accounting standards have developed over time to provide a more and more comparable view of the financial state of a company, making them a more and more thrustworthy source for determining creditworthiness. To better enable comparisons of companies with different sizes, financials are often represented as ratios.

Financial Ratios

Financial ratios are being used for credit risk analyses throughout the financial industry and present the basic characteristics of companies. A number of these ratios represent (directly or indirectly) creditworthiness. Zanders’ Corporate Credit Rating model uses the most common of these financial ratios, which can be categorised in five pillars:

Pillar 1 - Operations

The Operations pillar consists of variables that consider the profitability and ability of a company to influence its profitability. Earnings power is a main determinant of the success or failure of a company. It measures the ability of a company to create economic value and the ability to give risk protection to its creditors. Recurrent profitability is a main line of defense against debtor-, market-, operational- and business risk losses. 

Turnover Growth

Turnover growth is defined as the annual percentage change in Turnover, expressed as a percentage. It indicates the growth rate of a company. Both very low and very high values tend to indicate low credit quality. For low turnover growth this is clear. High turnover growth can be an indication for a risky business strategy or a start-up company with a business model that has not been tested over time.

Gross Margin

Gross margin is defined as Gross profit divided by Turnover, expressed as a percentage. The gross margin indicates the profitability of a company. It measures how much a company earns, taking into consideration the costs that it incurs for producing its products and/or services. A higher Gross margin implies a lower default probability.

Operating Margin

Operating margin is defined as Earnings before Interest and Taxes (EBIT) divided by Turnover, expressed as a percentage. This ratio indicates the profitability of the company. Operating margin is a measurement of what proportion of a company's revenue is left over after paying for variable costs of production such as wages, raw materials, etc. A healthy Operating margin is required for a company to be able to pay for its fixed costs, such as interest on debt. A higher Operating margin implies a lower default probability.

Return on Sales

Return on sales is defined as P/L for period (Net income) divided by Turnover, expressed as a percentage. Return on sales = P/L for period (Net income) / Turnover x 100%. Return on sales indicates how much profit, net of all expenses, is being produced per pound of sales. Return on sales is also known as net profit margin. A higher Return on sales implies a lower default probability.

Return on Capital Employed

Return on capital employed (ROCE) is defined as Earnings before Interest and Taxes (EBIT) divided by Total assets minus Current liabilities, expressed as a percentage. This ratio indicates how successful management has been in generating profits (before Financing costs) with all of the cash resources provided to them which carry a cost, i.e. equity plus debt. It is a basic measure of the overall performance, combining margins and efficiency in asset utilization. A higher ROCE implies a lower default probability.

Pillar 2 - Liquidity

The Liquidity pillar assesses the ability of a company to become liquid in the short-term. Illiquidity is almost always a direct cause of a failure, while a strong liquidity helps a company to remain sufficiently funded in times of distress. The liquidity pillar consists of variables that consider the ability of a company to convert an asset into cash quickly and without any price discount to meet its obligations. 

Current Ratio

Current ratio is defined as Current assets, including Cash and Cash equivalents, divided by Current liabilities, expressed as a number. This ratio is a rough indication of a firm's ability to service its current obligations. Generally, the higher the Current ratio, the greater the cushion between current obligations and a firm's ability to pay them. A stronger ratio reflects a numerical superiority of Current assets over Current liabilities. However, the composition and quality of Current assets are a critical factor in the analysis of an individual firm's liquidity, which is why the current ratio assessment should be considered in conjunction with the overall liquidity assessment. A higher Current ratio implies a lower default probability. 

Quick Ratio

The Quick ratio (also known as the Acid test ratio) is defined as Current assets, including Cash and Cash equivalents, minus Stock divided by Current liabilities, expressed as a number. The ratio indicates the degree to which a company's Current liabilities are covered by the most liquid Current assets. It is a refinement of the Current ratio and is a more conservative measure of liquidity. Generally, any value of less than 1 to 1 implies a reciprocal dependency on inventory or other current assets to liquidate short-term debt. A higher Quick ratio implies a lower default probability.

Stock Days 

Stock days is defined as the average Stock during the year times the number of days in a year divided by the Cost of goods sold, expressed as a number. This ratio indicates the average length of time that units are in stock. A low ratio is a sign of good liquidity or superior merchandising. A high ratio can be a sign of poor liquidity, possible overstocking, obsolescence, or, in contrast to these negative interpretations, a planned stock build-up in the case of material shortages. A higher Stock days ratio implies a higher default probability.

Debtor Days

Debtor days is defined as the average Debtors during the year times the number of days in a year divided by Turnover. Debtor days indicates the average number of days that trade debtors are outstanding. Generally, the greater number of days outstanding, the greater the probability of delinquencies in trade debtors and the more cash resources are absorbed. If a company's debtors appear to be turning slower than the industry, further research is needed and the quality of the debtors should be examined closely. A higher Debtors days ratio implies a higher default probability.

Creditor Days

Creditor days is defined as the average Creditors during the year as a fraction of the Cost of goods sold times the number of days in a year. It indicates the average length of time the company's trade debt is outstanding. If a company's Creditors days appear to be turning more slowly than the industry, then the company may be experiencing cash shortages, disputing invoices with suppliers, enjoying extended terms, or deliberately expanding its trade credit. The ratio comparison of company to industry suggests the existence of these or other causes. A higher Creditors days ratio implies a higher default probability.

Pillar 3 - Capital Structure

The Capital pillar considers how a company is financed. Capital should be sufficient to cover expected and unexpected losses. Strong capital levels provide management with financial flexibility to take advantage of certain acquisition opportunities or allow discontinuation of business lines with associated write offs.  

Gearing

Gearing is defined as Total debt divided by Tangible net worth, expressed as a percentage. It indicates the company’s reliance on (often expensive) interest bearing debt. In smaller companies, it also highlights the owners' stake in the business relative to the banks. A higher Gearing ratio implies a higher default probability.

Solvency

Solvency is defined as Tangible net worth (Shareholder funds – Intangibles) divided by Total assets – Intangibles, expressed as a percentage. It indicates the financial leverage of a company, i.e. it measures how much a company is relying on creditors to fund assets. The lower the ratio, the greater the financial risk. The amount of risk considered acceptable for a company depends on the nature of the business and the skills of its management, the liquidity of the assets and speed of the asset conversion cycle, and the stability of revenues and cash flows. A higher Solvency ratio implies a lower default probability.

Pillar 4 - Debt Service

The debt service pillar considers the capability of a company to meet its financial obligations in the form of debt. It ties the debt obligation a company has to its earnings potential. 

Total Debt / EBITDA

The debt service pillar considers the capability of a company to meet its financial obligations. This ratio is defined as Total debt divided by Earnings before Interest, Taxes, Depreciation, and Amortization (EBITDA). Total debt comprises Loans + Noncurrent liabilities. It indicates the total debt run-off period by showing the number of years it would take to repay all of the company's interest-bearing debt from operating profit adjusted for Depreciation and Amortization. However, EBITDA should not, of course, be considered as cash available to pay off debt. A higher Debt service ratio implies a higher default probability. 

Interest Coverage Ratio

Interest coverage ratio is defined as Earnings before interest and taxes (EBIT) divided by interest expenses (Gross and Capitalized). It indicates the firm's ability to meet interest payments from earnings. A high ratio indicates that the borrower should have little difficulty in meeting the interest obligations of loans. This ratio also serves as an indicator of a firm's ability to service current debt and its capacity for taking on additional debt. A higher Interest coverage ratio implies a lower default probability.

Pillar 5 - Size

In general, the larger a company is, the less vulnerable the company is, as there is, usually, more diversification in turnover. Turnover is considered the best indicator of size. In general, turnover is related to vulnerability. The higher the turnover, the less vulnerable a company (generally) is.

Ratio Scoring and Mapping

While these financial ratios provide some very useful information regarding the current state of a company, it is difficult to assess them on a stand-alone basis. They are only useful in a credit rating determination if we can compare them to the same ratios for a group of peers. Ratio scoring deals with the process of translating the financials to a score that gives an indication of the relative creditworthiness of a company against its peers.

The ratios are assessed against a peer group of companies. This provides more discriminatory power during the calibration process and hence a better estimation of the risk that a company will default. Research has shown that there are two factors that are most fundamental when determining a comparable peer group. These two factors are industry type and size. The financial ratios tend to behave ‘most alike’ within these segmentations. The industry type is a good way to separate, for example, companies with a lot of tangible assets on their balance sheet (e.g. retail) versus companies with very few tangible assets (e.g. service based industries). The size reflects that larger companies are generally more robust and less likely to default in the short to medium term, as compared to smaller, less mature companies.

Since ratios tend to behave differently over different industries and sizes, the ratio value score has to be calibrated for each peer group segment.

When scoring a ratio, both the latest value and the long-term trend should be taken into account. The trend reflects whether a company’s financials are improving or deteriorating over time, which may be an indication of their long-term perspective. Hence, trends are also taken into account as a separate factor in the scoring function.

To arrive to a total score, a set of weights needs to be determined, which indicates the relative importance of the different components. This total score is then mapped to a ordinal rating scale, which usually runs from AAA (excellent creditworthiness) to D (defaulted) to indicate the creditworthiness. Note that at this stage, the rating only incorporates the quantitative factors. It will serve as a starting point to include the qualitative factors and the overrides.

"A sound credit rating model strikes a balance between quantitative and qualitative aspects. Relying too much on quantitative outcomes ignores valuable ‘unstructured’ information, whereas an expert judgement based approach ignores the value of empirical data, and their explanatory power."

Qualitative Factors

Qualitative factors are crucial to include in the model. They capture the ‘softer’ criteria underlying creditworthiness. They relate, among others, to the track record, management capabilities, accounting standards and access to capital of a company. These can be hard to capture in concrete criteria, and they will differ between different credit rating models.

Note that due to their qualitative nature, these factors will rely more on expert opinion and industry insights. Furthermore, some of these factors will affect larger companies more than smaller companies and vice versa. In larger companies, management structures are far more complex, track records will tend to be more extensive and access to capital is a more prominent consideration.

All factors are generally assigned an ordinal scoring scale and relative weights, to arrive at a total score for the qualitative part of the assessment.

A categorisation can be made between business analysis and behavioural analysis.

Business Analysis

Business analysis deals with all aspects of a company that relate to the way they operate in the markets. Some of the factors that can be included in a credit rating model are the following:

Years in Same Business

Companies that have operated in the same line of business for a prolonged period of time have increased credibility of staying around for the foreseeable future. Their business model is sound enough to generate stable financials.

Customer Risk

Customer risk is an assessment to what extent a company is dependent on one or a small group of customers for their turnover. A large customer taking its business to a competitor can have a significant impact on such a company.

Accounting Risk

The companies internal accounting standards are generally a good indicator of the quality of management and internal controls. Recent or frequent incidents, delayed annual reports and a lack of detail are clear red flags.

Track record with Corporate

This is mostly relevant for counterparties with whom a standing relationship exists. The track record of previous years is useful first hand experience to take into account when assessing the creditworthiness.

Continuity of Management

A company that has been under the same management for an extended period of time tends to reflect a stable company, with few internal struggles. Furthermore, this reflects a positive assessment of management by the shareholders.

Operating Activities Area

Companies operating on a global scale are generally more diversified and therefore less affected by most political and regulatory risks. This reflects well in their credit rating. Additionally, companies that serve a large market have a solid base that provides some security against adverse events.

Access to Capital

Access to capital is a crucial element of the qualitative assessment. Companies with a good access to the capital markets can raise debt and equity as needed. An actively traded stock, a public rating and frequent and recent debt issuances are all signals that a company has access to capital.

Behavioral Analysis

Behavioural analysis aims to incorporate prior behaviour of a company in the credit rating. A separation can be made between external and internal indicators

External indicators

External indicators are all information that can be acquired from external parties, relating to the behaviour of a company where it comes to honouring obligations. This could be a credit rapport from a credit rating agency, payment details from a bank, public news items, etcetera.

Internal Indicators

Internal indicators concern all prior interactions you have had with a company. This includes payment delay, litigation, breaches of financial covenants etcetera.

Override Framework

Many models allow for an override of the credit rating resulting from the prior analysis. This is a more discretionary step, which should be properly substantiated and documented. Overrides generally only allow for adjusting the credit rating with one notch upward, while downward adjustment can be more sizable.

Overrides can be made due to a variety of reasons, which is generally carefully separated in the model. Reasons for overrides generally include adjusting for country risk, industry adjustments, company specific risk and group support.

It should be noted that some overrides are mandated by governing bodies. As an example, the OECD prescribes the overrides to be applied based on a country risk mapping table, for the purpose of arm’s length pricing of intercompany contracts.

Combining all the factors and considerations mentioned in this article, applying weights and scoring functions and applying overrides, a final credit rating results.

Model Quality and Fit

The model quality determines whether the model is appropriate to be used in a practical setting. From a statistical modelling perspective, a lot of considerations can be made with regard to model quality, which are outside of the scope of this article, so we will stick to a high level consideration here.

The AUC (area under the ROC curve) metric is one of the most popular metrics to quantify the model fit (note this is not necessarily the same as the model quality, just as correlation does not equal causation). The AUC metric indicates, very simply put, the number of correct and incorrect predictions and plots them in a graph. The area under that graph then indicates the explanatory power of the model. A more extensive guide to the AUC metric can be found here.

Alternative Modelling Approaches

The model structure described above is one specific way to model credit ratings. While models may widely vary, most of these components would typically be included. During recent years, there has been an increase in the use of payment data, which is disclosed through the PSD2 regulation. This can provide a more up-to-date overview of the state of the company and can definitely be considered as an additional factor in the analysis. However, the main disadvantage of this approach is that it requires explicit approval from the counterparty to use the data, which makes it more challenging to apply on a portfolio basis.

Another approach is a purely machine learning based modelling approach. If applied well, this will give the best model in terms of the AUC (area under the curve) metric, which measures the explanatory power of the model. One major disadvantage of this approach, however, is that the interpretability of the resulting model is very limited. This is something that is generally not preferred by auditors and regulatory bodies as the primary model for creditworthiness. In practice, we see these models most often as challenger models, to benchmark the explanatory power of models based on economic rationale. They can serve to spot deficiencies in the explanatory power of existing models and trigger a re-assessment of the factors included in these models. In some cases, they may also be used to create additional comfort regarding the inclusion of some factors.

Furthermore, the degree to which the model depends on expert opinion is to a large extent dependent on the data available to the model developer. Most notably, the financials and historical default data of a representative group of companies is needed to properly fit the model to the empirical data. Since this data can be hard to come by, many credit rating models are based more on expert opinion than actual quantitative data. Our Corporate Credit Rating model was calibrated on a database containing the financials and default data of an extensive set of companies. This provides a solid quantitative basis for the model outcomes.

Closing Remarks

Model credit risk and credit ratings is a complex affair. Zanders provides advice, standardized and customizable models and software solutions to tackle these challenges. Do you want to learn more about credit rating modelling? Reach out for a free consultation. Looking for a tailor made and flexible solution to become IFRS 9 compliant, find out about our Condor Credit Risk Suite, the IFRS9 compliance solution.